Regulatory Update
How to Write a Compliant Subcontract for a Commercial Item Under FAR Part 12
The FAR technically retired the term “commercial item.” A few years back it split into two defined terms, commercial product and commercial service, both at FAR 2.101. Everyone in the industry, including us in the title of this post, still says “commercial item” out of habit. That’s fine as shorthand. The problem is when a subcontract template still reflects the old, looser…
Read MoreCMMC Phase II Is Suspended. Your FAR, DFARS, and CAS Obligations Are Not.
On July 13, 2026, the Department of Defense announced the immediate suspension of CMMC Phase II. This third-party cybersecurity assessment requirement was scheduled to take effect on November 10, 2026. DoD CIO Kirsten Davies is forming a 60-day CMMC Reform Task Force to review the certification program. For now, no one knows what the program…
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